Question
(redacted) (Redacted)
July 18, 1984
Wayne E. Kaplan, Esq.
Pre-Merger Notification Office
Federal Trade Commission
Federal Trade Commission Bldg., Room 301
6th Street & Pennsylvania Avenue, N.W.
Washington, D.C. 20580
Dear Mr. Kaplan:
Thank you for calling. I understand that our correspondence to your office on July 16, 1984 accurately reflects the guidance you have given as to certain interpretations of the Hart-Scott-Rodino Antitrust Improvements Act and accompanying regulations.
As you point out, it is my understanding that the value of any non-monetary assets (e.g., building, equipment) contributed by the partners to the partnership is to be considered in determining whether the size-of-person requirement for an acquiring person has been met under 7A(2) of the Clayton Act.
Thank you for your attention to this matter.
Very truly yours,
(Redacted)
(Redacted)